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Mandatory Consultation Statement
Local Authorities
Aberdeen City Council: Enhanced community engagement is welcomed. However, neighbour notification is likely to target those who may have concerns about an allocation rather than the wider community where support may lie. It is suggested that other additional methods of consultation may be needed to try to reach a wider public. There are also significant resource implications of both carrying out the neighbour notification process and dealing with the responses.
City of Edinburgh Council: Support as development of current practice in preparing summary of consultations. More rigorous approach to engaging difficult to reach groups needed.
Comhairle Nan Eilean Siar: The productions of such statements have been part of the system to date and bringing the statement into the development plan scheme would assist in the awareness raising process. Again, the consultation statement should not be complicated in terms of procedures introduced.
East Dunbartonshire Council: A statement of consultation is already issued by East Dunbartonshire Council with each plan, although updating it annually will require additional resources.
East Renfrewshire Council: Accepted in principle. However, the role of the reporter in assessing the extent to which the Council has fulfilled its consultation statement obligations needs to be carefully defined and publicised.
Inverclyde Council: This appears to be an improvement on what is already largely done, but it is not clear what the significance of the proposal is. It is likely to require more work and more auditing by SEDD, which is not always welcome.
Moray Council: The White Paper only recommends 'enhanced procedures' to increase the level of inclusiveness. It avoids stipulating specific new measures to require inclusiveness, so practice will continue to vary widely between authorities. Moray has a good record in making the public aware of its Development Plan but whole important areas can go unremarked until there is a specific proposal.
West Dunbartonshire Council: Consultation with the public and local groups is currently important but it will require even greater efforts under the new regime. This requirement is acceptable and the examination of its content will ensure that comprehensive efforts are made to engage local people throughout the plan preparation process.
Other LA Organisations
Glasgow and the Clyde Valley Structure Plan Joint Committee:
The provision of the White Paper will dictate that a clear programme of participation and consultation be agreed and published as part of the Development Plan Scheme. This will then allow stakeholders to hold the Joint Committee to its published approach in the knowledge that representation can be made to the Reporter at the Examination as to their satisfaction with the process. The net outcome is effectively that the Joint Committee and its Authorities address and agree and publish at an earlier stage in the Plan cycle, the programme and process, including innovative practices, of consultation.
Non Departmental Public Bodies
Historic Environment Council for Scotland:HEACS recognises that there are considerable benefits in ensuring that the local plan mechanism will be overhauled and made the effective tool that it had always intended to be; it notes and welcomes the degree to which there is to be enhanced consultation before the publication of any plan, though this must be based on a realistic assessment of the capability of communities to cope with this enhanced role. There are many aspects of the historic environment for which there is presently no statutory protection, for which the only effective protection is through the local plan. As expressions of local identity these can be of considerable importance to Scotland's many and varied communities.
Other Public Bodies
Central Scotland Forest Trust: We support this proposal but believe there may be a need for some monitoring of consultation statement implementation ( e.g. by the Scottish Executive Enquiry Reporters Unit), independently of objections, to ensure effective public consultation.
Strathclyde Passenger Transport: This requirement suggests that local authorities will need to engage with local people to demonstrate that they have fulfilled their commitments. Experience suggests that for the majority of people, the relatively long-term horizon and the abstract nature of development plans interests only a very limited number of people in the community. This is in part a lack of awareness of the inter-linkages between the NPF, local housing strategies, local transport plans, and so on, which help to make the contents of the plan meaningful. Consequently, putting effort into such exercises can be very costly and unrewarding. The Scottish Executive might wish to consider for planning authorities to be required to consult the Community Planning Partnerships and their subordinate partnership structures and community groups instead. In so doing, planning authorities should find that they are dealing with high level stakeholders and the broad spectrum of community representatives will be able to make constructive responses to development plans. Local communities on such groups usually develop the capacity to understand and relate to development plan consultation far more effectively because they are exposed to day to day activities of local government and other public sector stakeholders. Should there be an issue which such groups consider requires more detailed consultation with local people, they are far better placed to focus where and when that consultation should occur. Other organisations such as Community Councils which can also respond to high level strategies should also be included in consultations.
Development Industry
EDI Group Ltd: The extent to which the planning authority has engaged with local people will be tested when Examinations are held into Development Plans. Wider public participation has been sought before at this level. Encouragement should be given to community organisations to ensure that they are as truly representative as possible. More imaginative ideas are required to seek the opinions of those who do not usually engage with the development planning system.
Walker Group (Scotland) Ltd: Listening to local people is a laudable aim, however what if the local people have nothing to say. Recent experience in Stirling (Local Plan Alteration No.2, Consultative Draft Stage), where 10,000 detailed newsletters were posted through letterboxes to inform local people about the choices for a major growth area on their doorstep, resulted in only 200 responses (2%) being returned. Provided the "listening" does not result in unnecessary delays in the process this is acceptable.
Waterfront Edinburgh: The proposal for mandatory consultation with local people needs to be managed by the planning authority so that consultation on any aspect of the development plan associated with the Granton Waterfront major project is coordinated with consultation undertaken through the planning application/ EIA process to avoid over consulting local people. It is not just planning issues on which consultation is expected by Scottish Executive.
Other Business
Scottish Environmental Services Association ( SESA): There is an inherent contradiction within waste management planning: public opposition to all new waste management facilities is growing at a time when they operate to higher environmental standards, there is widespread support for a more resource efficient economy and our Members engage more with the public, than ever before. The White Paper must emphasise that the main objective of consultation is to make a decision.
Planning Consultants, Architects and Lawyers
Collar, Neil: The proposal for planning authorities to negotiate and mediate before the examination stage needs to take account of the resources available to them. The introduction of neighbour notification could increase significantly the amount of objections received. There will also be time pressure given the need to adopt the plan within the 5 year time period. Unless significant resources are made available, there might not be time to negotiate/ mediate with every objector.
GVA Grimley LLP: Welcome the proposed introduction of Consultation Statements to be prepared by local authorities for development plans, but again suggest that guidance on consultation procedures for SPG is included.
Community Councils
Garioch Area Forum of Community Councils: The explanation of the consultation statement is insufficiently precise to allay suspicions that communities may be sidelined during the process. We are of the firm opinion that Community Councils must be added to the list of statutory consultees for any planning application or inquiry, and that their opinions should receive serious consideration. At present Community Councils do not feel that their opinions carry much weight, and nothing in the draft White Paper leads us to believe that the situation will improve in the future.
Helensburgh Community Council: The HCC supports the requirement that each planning authority should provide a "consultation statement" explaining how it will engage local people in the development plan process. However there should also be a requirement that local groups, especially community councils, should be involved at an early point in creating that statement. 'Plan Preparation Groups' (including authority councillors, community councillors and representatives of other local community groups) could be integral to this process. The HCC supports the requirement that the authority must demonstrate that it has had "public participation" in the formulation of development plans. There should also be a requirement that a section of the Statement should be left to local community groups, especially community councils, to give their perceptions of the extent to which there has in fact been meaningful public involvement.
Kinghorn Community Council: Much of the problem with development planning has been the lack of meaningful open consultation prior to drafting of the plan. A key must be that those that draft reflect the 'whole' not just the policy views of the councillor the 'perceived' needs, without actually asking people.
Portobello Community Council (and Amenity Society): The main concern is the extent and effectiveness of public involvement in the new system, in which development plans will have far greater influence and power than before. The paper states that a wide range of measures will be introduced that "will give local people confidence that their views have been properly considered". What will these measures actually be and will they work?
Voluntary Organisations
Brethren Gospel Trusts: We support the reinforcement of the requirement to consult the local community in the development plan process. A 'consultation statement' is supported. In particular, local planning authorities should be required to consult widely including the faith community, who are amongst 'hard to reach' groups.
Edinburgh World Heritage: Public engagement, particularly in the early stages of development planning is to be commended but it is important to recognise firstly the resource implications, and secondly that this should start from an understanding of the qualities and a sense of the place if this is to succeed in involving local communities in developing spatial and land use policy.
Gatehouse Development Initiative: Your proposals under 5.3.3 state that, "people need to know that their views will be taken fully into account". How do you propose to do this? The only effective way is to carry out a plebiscite or referendum on each new Development Plan. The new Bill must require planners to observe results of the plebiscite.
Greenspace Scotland: We would highlight that this commitment to "meaningful public involvement' does not sit comfortably with the requirement (on page 28) to produce a "consultation statement" -there is a significant different between 'consultation' and 'involvement'.
Planning Aid Scotland: This is a useful proposal in bringing greater transparency to the development plan programme but it will not necessarily improve community engagement at an early stage in the programme. There is a need to produce specific standards for community engagement to ensure that planning authorities deliver the cultural shift in community engagement. The standards for community engagement produced by Communities Scotland are a useful starting point in this exercise but they need to be improved with better targeting, measurable indicators and a programme of monitoring and evaluation.
Pollokshields Heritage: We welcome the streamlined production process, including front loading the consultation process, as long as there is proper pre-plan consultation with community groups [see also our comment on e-planning]. We also welcome a
mandatory public examination of plans where objections have not been resolved.
Scottish Council for National Parks: One of the problems currently faced by those wishing to engage in the development plan process is that many local authorities are charging substantial sums of money for printed copy of a plan - figures of £50 are not uncommon. If the new system is to be more inclusive it should be made clear to planning authorities that members of the public wishing to have a copy of the document should be supplied as of right. It is clearly helpful to have plans available in local libraries and to be able to obtain DVDs, CDs etc but not all people have access to computers and it is notoriously difficult to study complex issues on small electronic screens.
Private Individuals
Bridges, Roy Professor: It seems to me that the suggested 'consultation statements' ought to be required to indicate whether community councils are involved and if not, why not. On the broader questions of policy, it would often seem to be appropriate to consult community council opinion through Forums of community councils where they exist as they do in Aberdeenshire. If the machinery existed formally to engage community councils earlier on in the planning process, some of the head might be taken out of the campaign for a third party right of appeal in the system.
Milligan, James: Community inputs to Local plans should be secured, generally through local planning forums serviced by Local Authority planning officers. The forums would include Local Authority councillors for that community as well as representatives of Community councils, Business organisations and other special interest groups. The forums would be tasked to generate a Local Community Plan which would be required to take account of 'best practice' guides and other relevant national government and local authority policies. Such a Local Community Plan would feed into and reflect any wider 'Local Authority Plan' for the Local Authority area. It would have to be approved by the relevant Local Authority and by the Executive. Where the Local Authority rejected a Community Local Plan, the Community Plan Forum would have a Right of Appeal to the Executive. Where a governmental priority generated a proposed 'Bad Neighbour' development in conflict with an approved Local Community Plan, the Executive would require to offer a commensurate planning gain and receive parliamentary approval for its actions.
Turner, Barry: This is fine as a concept but how is it to be organised? Development Plans are to take on more importance but it is not easy to get people involved at this stage and some key proposals could slip through the net. There is a resource issue here. Also, very clear guidance will be required on procedures. I see a greater role here for Community Councils which have good links into the community and can represent a broad community view to balance the views of those (who usually have the loudest voices) with a specific interest in certain proposals. Help would, however, have to be given by Planning Aid for Scotland where professional advice is not already available.
Urquhart, Graham: I am all for enhanced and early consultation for all stakeholders in the planning process, however, there is a real danger that this becomes an empty charade with no cognizance taken of issues raised. I think there needs to be clear and unequivocal requirement to explain how concerns have been addressed or why they have been ignored. I also support more consultation at the development plan stage. However, my concern is that some people may simply object to almost everything and that in reality it is sometimes difficult for people to consider things in the abstract.
Walls, John: Inclusiveness is considered by the White Paper to be an important factor and a number of measures are proposed such as the pre-application consultations, new procedures for public participation, increased scrutiny with respect to public engagement and so on. With respect to development plans a great opportunity has been missed not to identify the Community Planning Partnerships as a mechanism for effective consultation. Their recent origin should not be seen as an impediment. My four decades of professional experience have shown that the majority of local people find it difficult to engage with plans with a five to twenty five year horizon. The timescales render the proposals abstract and particularly difficult to relate to as the public are unaware of national planning guidance, the local housing strategy, the local transport strategy, regeneration outcome agreements, etc. However, within the Community Planning Partnerships one has strategic stakeholders and community representatives who can respond constructively to development plan consultations. The former are able through their professional experience and skills and the local people through capacity building which is both provided and acquired 'on the job'.
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